In advance of its October 24, 2017 Open Meeting, the Federal Communications Commission (Commission) has released a Draft Report and Order (Draft Order) for Commission consideration that, if adopted, would eliminate the Section 43.62 annual International Traffic and Revenue Report  (International Traffic Report) and streamline the Section 43.62 annual Circuit Capacity Report (Circuit Capacity Report).  As we reported in March, the Commission previously released a notice of proposed rulemaking seeking comments on whether it should retain, modify or eliminate the annual International Traffic Report and Circuit Capacity Report filed by certain providers of international telecommunications.  The Draft Order is not final and may differ from the final item released after the Open Meeting.  However, if the Draft Order is adopted as currently drafted, it could offer some welcome relief for reporting international providers.

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The Federal Communications Commission (“Commission”) voted unanimously at its Open Meeting on September 27, 2017 to approve a Notice of Proposed Rulemaking (“NPRM”) that proposes exempting certain types of wireless providers from the hearing aid compatibility (“HAC”) reporting requirements.  The NPRM outlines possible revisions to the wireless HAC rules that would “reduce unnecessary regulatory burdens, particularly for non-nationwide service providers.”  The reporting requirements currently apply to facilities-based and reseller wireless service providers of all sizes and this rulemaking represents a prime opportunity for smaller wireless carriers to remove some burdensome reporting obligations, which have led to enforcement actions in the past. Comments will be due 30 days after publication of the NPRM in the Federal Register and reply comments will be due 45 days after publication.

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By Public Notice released Friday, the Federal Communications Commission (FCC or Commission) announced that Interstate Telecommunications Service Providers (ITSP) and Commercial Mobile Radio Service (CMRS) providers can now log in to preview the provider’s FY2017 regulatory fee data in the FCC’s Fee Filer system.  ITSPs and CMRS providers have limited time to request any revisions to the data on which fees are based and therefore are encouraged to review their proposed fee data in a timely manner.

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At its March 23, 2017 Open Meeting, the Federal Communications Commission (FCC or Commission) voted unanimously to adopt a notice of proposed rulemaking (NPRM) seeking comment on a proposal to reduce certain reporting requirements for international telecommunications service providers (International Service Providers). In particular, the FCC proposes to eliminate, in its entirety, the annual International Traffic and Revenue Report, in which International Service Providers report details regarding their international telecommunications services. The NPRM also seeks comments on ways to streamline the annual Circuit Capacity Report in which International Service Providers report on satellite, terrestrial, and submarine cable system usage and capacity.

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As we discussed in our earlier blog post, on March 31, 2016, the Federal Communications Commission (FCC or Commission) voted along party lines (3-2) to launch a notice of proposed rulemaking (NPRM) to establish privacy rules for Broadband Internet Access Service (BIAS) providers.  These proposals, if adopted, could impose prescriptive and complex privacy obligations that would be among the most extensive in the country.

Today we release a client advisory that provides a deep dive into the item and its key proposals and questions.  Comments on the NPRM are due on May 27, 2016, and reply comments are due on June 27, 2016.


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atelier-reseau-internet-mondeBy Public Notice released February 25, the Federal Communications Commission’s (“Commission” or “FCC”) International Bureau (“Bureau”) reminded filers that the annual Section 43.62 International Circuit Capacity Report (“International Capacity Report”) will be due by the traditional date of March 31.  (Last year, due to the timing of the new manual and implementation of the filing portal, the deadline was delayed one month on a one-time basis.)  The Public Notice identified some updates to the Section 43.62 filing manual (“43.62 Manual”) clarifying certain reporting requirements.  Most updates were ministerial but one is of more significance for properly completing the Circuit Capacity Report requirement. Accordingly, entities subject to the international Circuit Capacity Reporting requirement should carefully review the revised filing manual to determine the scope of their reporting obligations.
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It’s a new year and the FCC has just released its annual update to the FCC Form 499A.  Telecommunications providers must use the 2016 Form 499A to report calendar year 2015 revenues for purposes of calculating contributions to the federal Universal Service Fund and other revenue-based contribution requirements including TRS, LNP, NANP and annual

As we noted in a February post on our CommLawMonitor blog, the Federal Communications Commission’s (“FCC”) new Section 43.62 international reporting requirements became effective on February 11, 2015. Now the FCC has made clear that the upcoming filing deadline for the Section 43.62 (a) annual international circuit capacity reports is postponed one month from March 31 to April 30 — at least for this year. Because the new online filing portal has not been available, the FCC suspended the regular March 31 filing date. In a Public Notice issued March 9, 2015, the International Bureau announced the April 30 deadline and that the new online report filing portal will be open from March 30, 2015, to April 30, 2015 for submissions. The FCC urges circuit capacity holders to file their reports “as early as possible” in the filing window.


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iStock_000000295237LargeEarlier today, the Federal Communications Commission released an enforcement advisory reminding telecommunications carriers and interconnected VoIP providers of the upcoming annual customer proprietary network information (“CPNI”) certification due by March 2, 2015.  For Kelley Drye’s own advisory on this CPNI filing requirement, please see the attached alert.


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It’s time again for carriers to submit the annual Customer Proprietary Network Information (CPNI) certification to the FCC.  Telecommunications carriers and interconnected VoIP providers are required to certify annually their compliance with the FCC’s CPNI protection rules.  The 2014 report covers calendar year 2013 and will be due by March 3, 2014 (March 1 falls